Why is a Code of Ethics needed?

Although SMEs are not obliged by law to adopt a code of ethics or an anti-corruption policy, they are increasingly subject to integrity assessments by large clients, financial institutions or international partners. Banks and investors apply rigorous due diligence processes and require anti-corruption measures even from small companies. In addition, the introduction of such a code gives SMEs the opportunity to review their working methods and strengthen the enforcement of internal rules.

Code of ethics vs anti-corruption policy: two tools, complementary goals

The Code of Ethics sets out the general values and behaviours expected from employees, management and partners: integrity, fairness, respect, transparency. It covers the whole organisational culture and the way we relate to each other inside and outside the company.

Anti-corruption policy is a normative instrument of an applied nature, characterised by a high degree of technicality and specificity. It provides a clear definition of relevant operational concepts, such as bribery, undue influence, conflict of interest and transfers of undue advantage, including gifts or other forms of benefits. The policy also includes explicit procedural provisions on mechanisms for the identification, assessment and sanctioning of behaviours associated with acts of corruption, thereby contributing to strengthening organisational integrity and preventing reputational and legal risks.

Anti-corruption policy is thus an essential component of the code of ethics, but it does not replace it.

Recommended structure of a Code of Ethics

According to international guidelines for SMEs and the UN model, a clear and effective code of ethics can be structured as follows:

1. Introduction and purpose of the code - explains why the code has been developed and reaffirms the company's commitment to integrity and good practice. It states to whom it applies and how it contributes to the organisation's objectives.
2. Integrity and ethical behaviour - sets out employees' obligation to respect the law, reject corruption and act honestly and transparently in all professional situations.
3. Equality and respect - promotes fair treatment, non-discrimination, diversity and the fundamental rights of all employees and partners.
4. Health and safety at work - reaffirms the organisation's commitment to providing a safe and healthy working environment in accordance with legal and ethical standards.
5. Corruption prevention and governance - includes rules on conflicts of interest, undue influence and relations with public officials. Topics such as bribery, illegal kickbacks or influence peddling are clearly prohibited.
6. Relations with third parties - The code sets out rules on choosing and managing relationships with suppliers, consultants, agents and other partners, including due diligence and including ethical clauses in contracts.
7. Gifts and benefits - Only symbolic gifts of modest value are allowed, without influencing business decisions. Offering or accepting money or personal advantages is prohibited.
8. Reporting offences and whistleblower protection - gives employees the opportunity to report misconduct confidentially and without fear of retaliation. It defines the channels and responsibilities involved.
9. Enforcement and sanctions - provides for disciplinary measures for breaches of the code, emphasising the importance of equal and consistent application of the rules.

Practical benefits of a code of conduct

1. Strengthened reputation and confidence in external relations
   Companies that adopt a code of ethics and an anti-corruption policy gain the trust of large customers, financial institutions and authorities. These measures "protect the reputation" and "position SMEs favourably" in business and financing relationships.
2. Legal and financial risk prevention
   A single offence can result in fines, loss of contracts and costly court cases.
3. Improved access to markets and partnerships
   Adopting an anti-corruption policy is a clear advantage for SMEs when working with global companies subject to strict international regulations.
4. Increased efficiency and clarity of decision-making
   The code of ethics gives employees a clear reference for decision-making and contributes to better use of resources, avoiding biased or risky decisions.
5. Healthy organisational culture and internal motivation
   An integrity-based culture fosters employee engagement, reduces internal conflict and supports long-term performance.